BRSR for Banks and NBFCs — Material Disclosures, Financed Emissions, and the RBI Climate Framework Overlap

Why this guide exists

Indian banks and NBFCs sit in a distinctive position within the Top 1,000 listed-entity cohort — and within the Indian sustainability-disclosure landscape generally. They are simultaneously:

• In scope for BRSR under the SEBI LODR Regulation 34(2)(f) framework (the listed banks and listed NBFCs are subject to the same BRSR + BRSR Core phase-in as other listed entities)
• Subject to a parallel RBI climate-risk disclosure regime — the draft framework issued for consultation in February 2024 covers Scheduled Commercial Banks (SCBs), All-India Financial Institutions (AIFIs), tier-IV Urban Cooperative Banks, and top + upper layer NBFCs, with TCFD-aligned disclosures across Governance, Strategy, Risk Management, and Metrics & Targets

This guide walks through the BRSR-specific patterns observed for Indian listed banks and NBFCs — the Core attributes that tend to be most material in practice, the financed-emissions methodology context (Scope 3 Cat 15 under PCAF — typically a Leadership disclosure), the related-party-transaction interplay with the Openness of Business KPI, and how the BRSR submission interacts with the RBI climate framework.

This guide describes common BRSR disclosure patterns for the banking and NBFC sector, but entity-level materiality, current SEBI phase-in applicability, RBI applicability tier, and the assurance standard applied should always be confirmed for the specific listed entity.

The banking and NBFC profile within the Top 1,000

Common sectoral features observed in Indian listed banks’ and NBFCs’ BRSR disclosures (these shape the disclosure profile in practice but are not a SEBI-prescribed sector taxonomy):

• Service-sector NIC classification — Banks are typically classified under NIC 64 (Financial service activities, except insurance and pension funding); NBFCs typically map to the same NIC 64 series or to NIC 65 / 66 depending on the activity profile. The principal-services-by-turnover schedule is usually concentrated by product line (interest income, fee income, treasury, etc.).
• Branch network footprint — Listed banks (especially public-sector banks and large private-sector banks) commonly have multi-state branch networks spanning Tier 1, Tier 2, and Tier 3 / Tier 4 cities. The Section A operations disclosure can be lengthy, and the Job Creation in Smaller Towns Core KPI is often a positive disclosure for entities with substantial rural / semi-urban presence.
• Group financial-services structure — Many listed banks have NBFC, asset-management, life-insurance, general-insurance, and broking subsidiaries. The boundary basis applied for BRSR scope (typically operational control or financial control, drawn from the GHG Protocol Corporate Standard and the entity’s Ind AS 110 consolidation) should be applied consistently with the methodology guidance in the SEBI December 2024 Industry Standards on BRSR Core.
• Predominantly office and branch facility footprint — direct (Scope 1 + 2) emissions are typically lower per ₹ revenue than for manufacturing peers, dominated by office HVAC, branch lighting / cooling, data centres, and standby diesel-genset use. Water withdrawal is also typically low per ₹ revenue.
• Material Scope 3 exposure in Cat 15 (Investments) — for SCBs, AIFIs, and top + upper layer NBFCs, the financed-emissions inventory is frequently observed to be the most material Scope 3 category, often substantially larger than the entity’s own Scope 1 + 2 emissions. PCAF is a widely used calculation methodology in practice.
• Gender diversity and wage parity — the financial-services sector has visible gender-diversity reporting; the BRSR Core gross wages paid to women KPI and the Principle 5 gender-diversity disclosures are typically substantive. See Female Wages Disclosure.

Material BRSR Core attributes for banks and NBFCs

The BRSR Core (per SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023) is structured around 9 ESG attributes. The materiality of each attribute for a banking / NBFC entity is entity-specific, but the patterns commonly observed in published submissions are:

BRSR Core attribute	NGRBC Principle	Typical materiality for banks / NBFCs	Sector notes
GHG emission intensity per revenue (Scope 1 + 2)	P6	Generally lower intensity than manufacturing peers	Driven by branch + head-office HVAC, lighting, data-centre, diesel-genset use. See GHG emission intensity per revenue.
Water withdrawal intensity	P6	Generally low, mostly office and branch consumption	See Water withdrawal intensity.
Job creation in smaller towns	P8	Typically substantive for entities with rural / semi-urban branch networks	See Job Creation in Smaller Towns.
Openness of business (related-party transactions)	P1	Frequently observed as a material reporting area for banking groups with NBFC, AMC, insurance subsidiaries	Inter-group lending, treasury arrangements, shared services drive volumes. See Openness of Business.
Gross wages paid to women	P5	Typically substantive disclosure	Financial-services has visible gender-pay reporting. See Female wages disclosure.
Spend on wellbeing	P3	Typically moderate to substantive	Bank wellbeing programmes (health insurance, accident, parental leave) are usually well-funded. See Spend on Wellbeing.
Complaints disclosure (POSH)	P5	Typically substantive disclosure given workforce size	See POSH complaints disclosure.

The materiality table above reflects observed patterns from published Indian banking-sector BRSR submissions — entity-level materiality assessment is the framework that should drive the actual reporting emphasis. See the Materiality Assessment Walkthrough.

Financed emissions — Scope 3 Category 15

For banks, AIFIs, and large NBFCs, financed emissions are frequently observed to be the most material Scope 3 category, often substantially larger than the entity’s own Scope 1 + 2 emissions. They sit in Scope 3 Category 15 (Investments) under the GHG Protocol Corporate Value Chain Standard.

Methodology context (PCAF)

The Partnership for Carbon Accounting Financials (PCAF) is a widely recognised industry methodology for calculating financed emissions. PCAF defines an asset-class-specific approach for:

• Listed equity and corporate bonds — emissions × (FI’s outstanding investment / investee enterprise value)
• Business loans and unlisted equity — emissions × (FI’s outstanding loan / investee enterprise value or total equity + debt)
• Project finance — direct attribution of project emissions to the FI’s share of project debt + equity
• Mortgages — building-specific emissions × (FI’s outstanding mortgage / property value)
• Motor vehicle loans — vehicle-specific emissions × (FI’s outstanding loan / asset value)

PCAF also defines a five-level Data Quality Score (1 = highest quality, 5 = proxy estimates) which is itself disclosed alongside the absolute financed-emissions number. This data-quality dimension is important for the assurance conversation — an FI’s Cat 15 inventory built primarily on Score 4 / 5 data is a fundamentally different assurance proposition from one built on Score 1 / 2 verified borrower data.

Where financed emissions sit in BRSR

Comprehensive consolidated Scope 3 inventory under BRSR historically sits in Principle 6 Leadership (voluntary). However, per the SEBI BRSR Core circular dated 12 July 2023:

• Scope 3 GHG disclosure is required from the top 250 listed entities on a comply-or-explain basis from FY 2024–25, with assurance on Scope 3 phased from FY 2025–26 on the same basis.
• Value Chain ESG disclosures (covering top upstream and downstream partners cumulatively comprising 75% of purchases / sales by value, with the per-partner 2% materiality threshold) are also applicable to the top 250 from FY 2024–25 on a comply-or-explain basis. See the Value Chain Disclosure glossary entry for the scoping mechanics.

Many large Indian listed banks have begun publishing financed-emissions inventories using PCAF — typically alongside the broader Scope 3 / Value Chain disclosure required under BRSR Core, plus a separate, more detailed disclosure aligned with TCFD / the RBI draft Climate Disclosure Framework. The BRSR Core comply-or-explain framework, BRSR Principle 6 Leadership, and the RBI climate framework do not substitute for each other — many entities will need to map a single internal data model to all three regimes.

For methodology depth on Scope 3 calculation conventions for service-sector entities (which extends to banks for their non-Cat-15 Scope 3 categories — Cat 6 Business Travel, Cat 7 Employee Commuting, Cat 1 Purchased Goods and Services), see the Scope 3 for Service Companies guide.

RBI Climate Disclosure Framework — separate but adjacent

The RBI’s Draft Disclosure Framework on Climate-related Financial Risks (issued for consultation in February 2024) is a TCFD-aligned disclosure regime distinct from BRSR but operationally adjacent for entities that are both RBI-regulated and SEBI-listed. Key points (per the published draft):

• Applicability: Scheduled Commercial Banks (SCBs), All-India Financial Institutions (AIFIs), tier-IV Urban Cooperative Banks, and the top + upper layer NBFCs per RBI’s NBFC scale-based regulation.
• Four-pillar structure aligned with TCFD: Governance, Strategy, Risk Management, and Metrics & Targets.
• Baseline vs Enhanced disclosures — SCBs, AIFIs, and applicable NBFCs report both baseline and enhanced; tier-IV UCBs report baseline at minimum (enhanced voluntary).
• Financed-emissions disclosure by industry and asset class is contemplated under Metrics & Targets, with phased implementation starting FY 2025–26 and more granular metrics from FY 2027–28 per the published consultation framework.

The RBI framework and BRSR are independent. Filing one does not satisfy the other. In practice, listed banks and NBFCs typically build a single internal data model that supports both — same underlying GHG inventory, same financed-emissions calculation, sliced and presented per each regime’s prescribed format.

Section A patterns specific to banks and NBFCs

Several distinctive patterns:

1. Products-and-services breakdown — typically organised by product line (interest income from advances, treasury income, fee-based income, etc.), often concentrated in two or three categories that account for most turnover.
2. Operational locations — for branched banks, the Section A operations disclosure can be very lengthy (state-wise + UT-wise branch counts). Many entities supply the full branch register as an annexure.
3. Workforce structure — banks and NBFCs typically have a multi-tier workforce: permanent employees (officers + clerical + sub-staff for banks), contract employees, business correspondents (for banks with rural reach), and outsourced workers. The mapping into BRSR’s employee / worker categorisation (and male / female / disability splits) is usually a documented internal mapping table — see the BRSR Section A Pre-fill Workflow for the operational walkthrough.
4. Subsidiary / group structure — listed banking groups frequently have NBFC, asset-management, life-insurance, general-insurance, broking, and overseas-banking subsidiaries. The boundary basis applied for BRSR scope (operational control, financial control, equity-share) is typically drawn from the GHG Protocol Corporate Standard and the entity’s Ind AS 110 consolidation, and should be applied consistently with the methodology guidance in the SEBI December 2024 Industry Standards on BRSR Core.
5. CSR spend — Section 135 of the Companies Act 2013 commonly applies to large listed banks and NBFCs given their financial position; the Section A CSR block is typically substantive when applicable. Refer to Section 135 of the Companies Act and applicable Companies (CSR Policy) Rules for the specific applicability tests.

How Batchwise fits

Batchwise coordinates BRSR Core Assurance for listed banks and NBFCs through its partner CA firm network. The BRSR Core sign-off is delivered under partner CA firm letterhead and DSC; Batchwise handles the operational layer — buyer onboarding, evidence ingestion via the document portal, partner CA firm assignment, status tracking, and 72-hour SLA on the coordinated end-to-end. For banks and NBFCs that also need ISAE 3410 GHG verification (typically for the financed-emissions inventory presented under BRSR Principle 6 Leadership or under the RBI framework), Batchwise coordinates that engagement separately under the same partner-CA-firm model.

See also: Document and Evidence Requirements for the artifacts the assurance provider expects, and BRSR vs Integrated Reporting for the broader corporate-reporting context that listed banks navigate.